ML20064M767
| ML20064M767 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/30/1982 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20064M691 | List: |
| References | |
| NUDOCS 8302150640 | |
| Download: ML20064M767 (5) | |
Text
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Goepa Power Company 333 Pecmort Avenun At:anta. Georgia 30308 Teor hor,e 404 526 6526 p G i.
rs-a Maorg Addmss Post Othce Bo= 4545 A!!anta_ Georg a 3030?
prp 9 hi9 4 o GeorgiaPower Power Generation Department November 30, 1982 U.S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII:
RFR Region II - Suite 3100 Inspection Report 101 Marietta Street, NW 50-321/82-32 Atlanta, Georgia 30303 50-366/82-30 ATTENTION: Mr. James P. O'Reilly Gentlemen:
The following is submitted as a response to I&E Inspection Report 50-321/82-32 and 50-366/82-30.
VIOLATION A:
Technical Specification 6.8.1 requires that procedures controlling the operation of safety-related systems be implemented.
Plant procedure HNP-1-3302-0, HPCI Valve Operability, steps B.2 and F.5 require that the High Pressure Coolant Injection (HPCI) Pump discharge valve (E41-F007) only be cycled during cold shutdown conditions during this surveillance procedure.
Contrary to the above, the HPCI system was not operated as required in that on September 24, 1982, during the performance of HNP-1-3302-0, the HPCI Pump discharge valve operator was energized to open while the unit was operating at hot pressurized conditions.
The subsequent failure of the valve motor operator may have been the result of the large differential pressure across the valve which existed because of plant conditions.
This is a Severity Level V Violation (Supplement I.).
This applies to Unit 1 only.
RESPONSE TO VIOLATION A:
Admission or denial of alleged violation:
The violation did occur, except that the valve in question was the HPCI Pump discharge valve E41-F006, rather than E41-F007.
Reason for Violation:
The violation was due to personnel error in that the operator did not follow plant procedure HNP-1-3302-0, "HPCI Valve Operability."
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Georgia Power d.
U. S. Nuclear Regulatory Connission Office of Inspection and Enforcement November 30, 1982 Page 2 Corrective Steps Which Have Been Taken and Results Achieved:
Due to the failure of the HPCI Pump discharge valve (E41-F006), the HPCI system was declared inoperable.
The Reactor Core Isolation Cooling (RCIC) system was already out of service for maintenance.
With both HPCI and RCIC inoperable, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Limiting Condition 'of Operation (LC0) was initiated in accordance with Unit 1 Technical Specification 3.5.D.3.
The plant was not shut down since the RCIC system was returned to service and was demonstrated operable within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
With HPCI inoperable, a 14-day LC0 was placed on the Unit per Technical 4
Specification 3.5.D.2.
The ADS actuation logic, the RCIC system, the Residual Heat Removal (RHR) system Low Pressure-Coolant Injection (LPCI) mode and the Core Spray system were demonstrated to be operable.- The operator was reprimanded for this incident and instructed to follow plant procedures per HNP-34, " Rules for Performing Procedures."
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The i
actions taken to date are sufficient to prevent a recurrence of the event.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on September 24, 1982.
VIOLATION B:
10 CFR 50.72 requires that the-NRC be notified promptly of significant events that occur at the facility.
The following examples constitute a severity level V violation against both units.
1.
10 CFR 50.72(a)(5) requires that with the occurrence of any event requiring initiation of a shutdown of the nuclear power plant in accordance with Technical Specification limiting conditions for operation, the NRC operations center shall be notified as soon as possible and in all cases within one hour.
Contrary to the above, the NRC operations center was not notified of a
reactor shutdown which was caused by the incorrect installation of humidity controllers on the Unit 1 Standby Gas a
Treatment system until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 49 minutes following the event on August 30, 1982.
2.
10 CFR 50.72(a)(7) requires that with the occurrence of any event resulting in automatic actuation of Engineered Safety Features, the NRC operations center shall be notified as soon as possible and in all cases within one hour.
ans
Geo iaPowerb U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement November 30,.1982 Page 3 VIOLATION B (Continued):
Contrary to the above, the NRC operations center was not notified j
of the actuation of the Unit 2 Core Spray and Low Pressure Coolant Injection systems due to a high drywell pressure condition subsequent to a Unit 2 reactor scram on August 25, 1982.
This is a severity Level V violation (Supplement I.).
This applies to Units 1 and 2.
RESPONSE TO VIOLATION B:
Admission or Denial of Alleged Violation: A violation did occur.
Reason for Violation:
At 0417 hours0.00483 days <br />0.116 hours <br />6.894841e-4 weeks <br />1.586685e-4 months <br /> on August 25, 1982, a reactor scram and Group 1 isolation occurred.
The NRC was notified of the scram and isolation in accordance with the requirements of 10 'CFR 50.72.
Subsequently, Core Spray and RHR were automatically actuated due to a high drywell pressure condition.
- However, operations supervision believed that the initial notification covered the subsequent events which were part of the same incident.
l Our understanding of the interpretation of 10 CFR 50.72 provided in the citation to Violation B.1 deviates from that which we believe is in consistent use throughout the industry.
Because of our concern over the potential implications of the interpretation set forth in the citation, we are considering making a request for a formal interpretation of the regulation by the NRC Counsel General. We believe the interpretation of 10 CFR 50.72, as used in this citation, would produce results which are contrary to the best interests of both the NRC and the industry.
To have events reported to the NRC without screening by the plant staff to determine reportability would both increase the NRC and industry staff's workloads and mask those significant reports, reducing the effectiveness of the one-hour reporting requirement.
We do not agree that item B.1 constitutes a valid example of a violation of 10 CFR 50.72.
The incorrectly installed humidity controllers were identified by a plant engineer as a deviation from expected plant condition at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on August 30, 1982.
The individual (i.e.,
engineer) discovering the deviation was not a licensed operator and may not have had knowledge of the reporting requirements of the Technical Specifications and 10 CFR 50.72. At 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on August 30, 1982, the Shift 700775
Georgia Power d UY S. Nuclear Regulatory Commission Office of Inspection and Enforcement November 30, 1982 Page 4 RESPONSE TO VIOLATION B (Continued):
Supervisor, a licensed individual, was notified of the deviation.
In the ensuing evaluation, it was determined that initiation of reactor shutdown was required, and at 1349 the NRC operations center was notified.
A period of 49 minutes elapsed between the identification of a deviation which required a reator shutdown and notification of the NRC operations center.
Therefore, a violation of 10 CFR 50.72 (a)(5) did not occur.
Corrective Steps Which Have Been Taken and Results Achieved:
As a result of our interpretation of 10 CFR 50.72, no immediate corrective steps were deemed necessary.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
A training directive will be issued to all personnel holding a Senior Reactor Operator's license detailing the reporting requirements of 10 CFR 50.72. This action will be completed by December 15, 1982.
Date When Full Compliance Will Be Achieved:
Full compliance was acheived on August 25, 1982.
VIOLATION C:
Technical Specification 6.8.1 requires that written procedures be implemented covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A.
Appendix "A" requires that radiation protection procedures be provided.
Procedure HNP-8009, Personnel Contamination Survey, step 3, describes the technique to be used to self monitor for personnel contamination with the RM-14 radiation monitor (frisker) and requires personnel to frisk themselves before passing locations where these instruments are located.
Contrary to the
- above, radiation protection procedures were not implemented in that on August 30, 1982, proper personnel frisking was not being performed at the entrance to the control building.
Following a licensee employee through the check point, the inspector noted that the RM-14 frisker at that location was turned off and unplugged.
This is a Severity Level V Violation (Supplement I.).
RESPONSE TO VIOLATION C:
Admission of Violation: The violation occurred.
Reason for Violation:
The violation occured when an employee f ailed to perform a proper frisk before entering the control room due to the frisker being turned off and unplugged.
The reason for the frisker being turned off and unplugged is unknown.
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Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement November 30, 1982 Page 5 RESPONSE TO VIOLATION C (Continued):
Per HNP-8009, an individual preparing to use a frisker should initially observe the meter reading to establish a background level.
If an individual finds the frisker not working properly, which is evident when the frisker is turned off, he should inform the Health Physics office so that corrective actions can be taken.
Corrective Steps Which Have Been Taken and the Results Achieved:
After an instrument check (as per HNP-8114) was performed, the frisker was returned to operation.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
Where appropriate, certain friskers inside the plant (such as at the access portal to the main control room) will have a security device to deter disconnection from its power supply.
Thus, it will be difficult to unplug or remove a frisker from its location.
Installation of these devices will be completed by January 15, 1983.
A copy of this notice of violation, plus response, will be distributed to each plant department and posted to remind each employee of his responsibility to perform a proper frisk and to follow radiation protection procedures.
Date When Full Compliance Was Achieved:
Full compliance was achieved on August 30, 1982 when the frisker was calibrated and returned to operation.
If you have any questions or need further information, please contact this office.
Very Truly Yours, h N &"
L. T. Gucwa Chief Nuclear Engineer xc: J. T. Beckha Jr.
H. C. Nix Senior Residen, Inspector 700775